Following guidance issued by the UK environment agency in July 2024, a revised approach to the application of the producer definition under the UK Waste Electrical and Electronic Equipment (WEEE) regulations has applied from the 2025 compliance period onwards.  

The clarification affects companies established outside the UK that place electrical and electronic equipment (EEE) on the UK market exclusively through indirect sales channels. While some non-UK companies had previously been permitted to register voluntarily as UK WEEE producers, this approach is no longer accepted. Instead, producer obligations must since then be assigned to the legal entity that meets the definition of a producer under the UK WEEE Regulations. 

Selling Directly or Indirectly  

The key distinction is whether a company sells directly or indirectly into the UK market. Direct selling refers to sales made directly to end-users, while indirect selling refers to sales made through importers, distributors or resellers. 

 From the 2025 compliance period onwards, non-UK companies that sell EEE into the UK exclusively through indirect sales channels are no longer considered UK WEEE producers. Instead, responsibility shifts to the first UK-established entity placing the products on the UK market. This means that the UK-based entity becomes responsible for:  

• Producer registration 
• Reporting EEE placed on the market 
• Financing the associated WEEE obligations  

Non-UK companies that sell directly to UK end-users can still qualify as producers and remain responsible for their own WEEE obligations.  

Why Was This Clarification Introduced?  

According to the UK environment agency, the revised approach is intended to ensure that producer obligations are assigned to the correct legal entity. It also aims to improve reporting accuracy, reduce the risk of double-counting EEE, simplify audits and support more effective enforcement.  

Online Marketplaces Have Taken on Extended Reporting Obligations  

The second key change concerns online marketplaces. Under the revised framework, online marketplace operators are now responsible for reporting the non-UK volumes sold via their platforms. The aim of this change is to improve data transparency whilst reducing duplicate reporting obligations. For this reason, since August 2025, non-UK businesses selling their products to end consumers in the UK via online marketplaces are no longer responsible for reporting these volumes.  

What Businesses Should Do Now  

If not already done, businesses selling EEE into the UK should review their sales models, reporting structures and contractual arrangements to ensure that producer obligations are assigned to the correct legal entity.  

For companies operating international distribution networks, understanding the distinction between direct and indirect sales is becoming increasingly important to maintain compliance and avoid reporting errors. Do you have any questions? Please do not hesitate to contact us. 

With the EU Packaging and Packaging Waste Regulation (PPWR) now in force and its requirements being phased in over the coming years, packaging labels are becoming a strategic infrastructure for the circular economy, compliance and waste management. The recently published proposal by the Joint Research Centre (JRC) for harmonised waste separation labels signals a significant shift: packaging must increasingly convey standardised information across Europe – both visually and digitally. Companies should start preparing for this now. 

The recently published proposal by the Joint Research Centre (JRC) for harmonised waste separation labels signals a significant shift: Packaging must increasingly convey standardised information across Europe – both visually and digitally. Companies should start preparing for this now. 

From Packaging Design to Circular Economy Infrastructure 

The aim of the new harmonised labelling is clear: to improve consumers’ willingness and ability to properly sort waste, increase collection and recycling rates, and promote packaging recycling on a large scale by 2035. Under Regulation (EU) 2025/40, packaging labelling will become a prerequisite for market access: Packaging across the EU must convey significantly more information and evolve from static information carriers into interfaces for packaging intelligence. 

What businesses need to know:

• Material composition must be clearly indicated using harmonised pictograms to simplify sorting 
• Reusable packaging requires special labelling
• Compostable packaging must be labelled separately
• Deposit-refund schemes such as PANT may retain national labelling but will also receive EU-wide harmonised colour-coded labelling
• Packaging containing recycled materials, bio-based plastics or substances of concern may require standardised digital identification technologies, including QR codes

The Timeline: Key Dates Companies Should Keep an Eye On 

The transition is taking place in stages, but the timeline is progressing rapidly. 

2026: The Framework Takes Shape 

By 12 August 2026, the European Commission is expected to set out specifications and formats for harmonised labelling. In addition, further requirements will come into force, including: 

• Identification features on packaging (type, batch or serial number) 
• Manufacturer details and contact information 
• Early use of QR codes as the recommended data infrastructure 

By the end of 2026, the Commission is also expected to publish findings on substances in packaging that could impair reuse, recycling and chemical safety. 

2027: Digital Labelling Could Be Extended 

From 2027, EU Member States may begin to require information on Extended Producer Responsibility (EPR) to be provided via QR codes. Where implemented at national level, these QR codes must comply with standardised EU formats. 

2028: Harmonised Labelling Becomes a Reality 

From 12 August 2028, exactly 24 months after the implementing acts enter into force, the key requirements will come into effect: 

• Harmonised pictograms indicating material composition 
• Information on the proportion of recycled material 
• Standardised digital labelling for substances of concern 
• Harmonised labelling for packaging covered by deposit-refund schemes 

This is likely to be one of the biggest operational changes in the packaging sector that many companies have faced in years. 

2029: Specific Requirements for Reusable Packaging 

From February 2029, reusable packaging placed on the market must bear a special label informing consumers about reuse schemes and how to use the product. As this can be supplemented by QR codes, it is advisable to leave space for QR codes. 

One thing is already becoming clear: If you are currently working on packaging redesign projects, you should reserve space for a QR code – ideally 10 x 10 mm or larger. If you wait until 2028 to adapt your packaging design, this could result in significant redesign costs and create avoidable implementation pressure. 

Please contact our team at PRONEXA if you need assistance or further information. 

For businesses, the disposal of batteries is becoming an ever-greater challenge. The rapid growth in consumer electronics, portable devices, small household appliances and energy storage systems for private households has led to an unprecedented rise in the volume of used batteries entering the recycling system. As more and more battery-powered products come into the market, waste streams are becoming even larger and significantly more complex. 

A key challenge for battery recycling is the increasing variety of batteries found in the waste streams from portable devices. Recycling facilities no longer process just a small number of standardised battery types. Instead, they must handle a growing variety of battery chemistries, formats and product designs. 

This development presents operational challenges for companies committed to safe and compliant waste disposal. Conventional sorting methods often struggle to keep pace with the speed, complexity and scale of modern battery waste streams. 

Safety Risks Rise in Line With Volume 

The increasing number of batteries entering recycling systems also brings new safety concerns. Damaged batteries can pose significant risks during collection, transport and processing. Batteries hidden within mixed waste streams may be punctured, crushed or self-ignite during handling processes. 

Lithium batteries, in particular, can pose serious risks if damaged, including thermal runaway and fires. For waste management companies and compliance managers, these risks can lead to operational disruptions, safety incidents and additional regulatory requirements. Given the ever-increasing volume of batteries, prevention and early detection are becoming increasingly important – not only in terms of efficiency, but also for workplace safety and regulatory compliance. 

AI Is Transforming the Battery Recycling Process 

In response to these challenges, there is a growing need for more reliable and intelligent approaches to identifying and sorting batteries. Artificial intelligence is emerging as one of the most promising technologies in this field. 

AI-powered sorting systems are revolutionising battery recycling by automating the identification and separation of end-of-life batteries. Rather than relying solely on manual inspections or traditional sorting techniques, AI-driven solutions combine advanced image detection with data-driven analysis to automate the sorting process for portable batteries – particularly according to battery chemistry. 

These systems analyse large volumes of material in real time and continuously improve through machine learning processes. This enables facilities to identify batteries more quickly and accurately, even in highly mixed material streams. 

Why Sorting by Battery Chemistry Is Important 

One of the greatest advantages of AI-powered systems is their ability to sort batteries by chemical type. This step is becoming increasingly important, as different battery chemistries require different recycling and processing methods. 

Accurate identification of the chemistry supports:

• More efficient recycling processes higher recovery rates of valuable materials 
• Lower risks of contamination 
• Improved operational safety 
• Better compliance with legal regulations 

Compliance Through Smarter Processes 

As battery technologies continue to evolve, manual sorting alone may no longer be sufficient to maintain high levels of accuracy and efficiency. For Producers, AI offers benefits that go beyond mere automation. Intelligent sorting systems can help create more transparent and standardised recycling workflows, whilst improving process reliability. As an emerging technology, AI is becoming a key tool for creating safer, smarter and more sustainable waste management processes that allow accurate identification of products, not only by chemistry, but also by brand – an important step also when it comes to moving into circular models in which producers would like to have their specific own products back. 

If you have any questions about battery sorting and your obligations as a manufacturer, please do not hesitate to contact us! 

After the first revision of WEEE Directive being published in 2012, European legislators have currently once again been reassessing its effectiveness and came to a clear conclusion: Changes are needed in order to 

• Slow down the growth of WEEE 
• Improve re-use and repair in order to prolong product lifecycles 
• Set incentives for sustainable product design.

The objective is clear: To make the legislation fit for purpose for the future and aligned with the broader ambitions of the circular economy.  

This review intends to reflect the changing realities of the market, including the emergence of new technologies (such as lithium-ion batteries and increasingly miniaturised components), new product categories (such as IoT devices, wearables and e-mobility equipment), as well as evolving waste streams, characterised by growing volumes of small electronic devices, a higher share of battery-containing products, and increasingly complex material compositions. Despite the progress made, nearly half of WEEE is still not properly collected, and only around 40% is effectively recycled. 

Key Questions Shaping the Future Framework 

As the revision process unfolds, the below fundamental questions are being discussed at EU level: 

• How can a better harmonisation and simplification be achieved across the Member States. Should WEEE remain a directive or be transposed into a regulation, as previously done both for Batteries as well as Packaging? 
• With the extraordinary importance for securing secondary raw material and need for critical raw material not being broadly available in Europe: Should WEEE continue as independent legislation or become integral part of the new Circular Economy Act? 

A clear direction from the European Commission is already emerging: greater harmonisation and simplification across the EU to reduce complexity and make EPR compliance easier for producers, especially when coming from the SME sector.

What Changes Can Be Expected? 

While the final shape of the revised WEEE framework is still under development, several key changes are already becoming apparent. The revision is expected to address amongst other the below structural weaknesses and to strengthen the circular economy performance of the legislation, including:

• Higher or revised collection targets for WEEE streams
• Stronger focus on recovering critical raw materials (CRMs), which are currently insufficiently captured in existing systems
• Attempt to harmonise Extended Producer Responsibility (EPR) schemes across Member States
• Improved reporting formats and greater transparency: Reduce national fragmentation through a regulation instead of a directive to ensure aligned implementation of law in all Member States
• Stronger enforcement measures, particularly regarding online sellers and free-riders.

Harmonisation: A Shared Objective 

The idea of simplification and harmonisation is not only driven by policymakers, but also strongly supported by PRONEXA and its PRO network across Europe. It has been a core principle from the beginning, when we were founded more than 10 years ago: Simplify EPR compliance for producers across Europe. Initially focussing on WEEE and Batteries, we now also cover Packaging obligations for our customers in 29 countries, with Switzerland as country number 30 expected to come up with Packaging EPR legislation, soon. 

Although not being able to harmonise legislation by ourselves, we successfully managed to implement a system that allows to handover the existing complexity to a reliable compliance partner, who manages that complexity on your behalf. 

What It Means for Producers 

For producers of electrical and electronic equipment, the upcoming revision of the WEEE Directive is both a challenge and an opportunity. On the one hand, the expected changes will force producers to increasingly amend the well-established linear business models into new circular ones. Common efforts will also be needed to achieve longer product life, easier recovery of material and the setup of functioning markets for secondary raw material. 

Whatever Changes Will Ultimately Be Implemented

• PRONEXA and our PRO network partners are monitoring regulatory developments closely 
• We are guiding producers when adaptations are needed 
• Independent from regulatory changes, we are offering already today a highly harmonised EPR requirements handling 
• Improving data quality and reporting capabilities will be required to adapt to the further requirements to be expected. 

At the same time, companies should consider how product design, recyclability, and material recovery strategies can support future compliance requirements – particularly in light of the growing focus on critical raw materials. 

The message is just as clear for businesses: those who prepare early will be best equipped to navigate the transition and benefit from a more harmonised European system.

Join PRONEXA on this journey and get in touch via the QUICK OBLIGATION CHECK if you would like further advice. 

Currently, consumers are confronted with a wide variety of symbols – such as the French TRIMAN label or country-specific systems in Italy and Spain – which often leads to confusion and incorrect disposal. Under Article 12 of the Packaging and Packaging Waste Regulation (PPWR), a standardised sorting label will be introduced for the first time across Europe. The goal is clear: 

• Reduce consumer confusion
• Improve sorting accuracy
• Increase recycling rates
• Remove barriers within the internal market

What Will Change? 

The proposal, developed by the Joint Research Centre (JRC), introduces a system designed to create labels that are intuitive and easy to understand at the point of disposal. The European Commission will review the JRC’s technical guidance, with final requirements expected by August 2028 through a planned implementing act. 

The system focuses on three key elements: 

1. Standardised pictograms: Clear, intuitive icons will indicate how packaging should be disposed of.
2. Harmonised colour coding: Consistent colours will be used across both packaging and collection bins to guide users.
3. Clear instructions: Labels will include straightforward guidance to reduce ambiguity at the point of disposal. 
4. Digital layer: QR codes provide localised and multilingual informations. 

Importantly, accessibility is a core principle. Colour coding is intended to support – not replace – pictograms and text, ensuring usability for people with visual or cognitive impairments. 

Digital Layer: Beyond Physical Labels 

Recognising the limitations of physical packaging space, the proposal also introduces digital solutions such as QR codes. These can provide: 

• Region-specific disposal instructions 
• Multilingual guidance 
• Additional sorting information 

For producers, this opens up new opportunities to connect local infrastructure with EU-wide standards while still addressing regional differences. 

The Technical Update As a Behavioural Challenge 

While the harmonisation of labels may appear to be a technical change, it is equally a behavioural challenge. Waste sorting habits are deeply influenced by local infrastructure, cultural norms, and user understanding. A unified system will only be effective if it is widely understood and consistently applied. 

The JRC proposal reflects this complexity. It is based on extensive research, including large-scale behavioural studies, stakeholder input from across the value chain, and co-creation with citizens in multiple Member States. This collaborative approach increases the likelihood that the system will work in practice, not just in theory. 

Implementation Challenges 

Despite its potential, implementation will require careful coordination. Aligning existing national systems with a new EU-wide framework will take time, and integrating elements such as deposit return schemes adds further complexity. There are also practical considerations around label clarity, the level of detail required, and the associated costs – particularly for smaller companies. 

To address these challenges, the proposal foresees transitional periods, continued stakeholder involvement, and strong communication efforts to support user adoption. 

What It Means for Producers 

For producers, the new labelling system presents a clear opportunity to improve sorting quality and overall system performance. At the same time, it requires active engagement. Operators will need to adapt their communication, align with new standards, and support public understanding of the changes. 

Opportunities: 
• Improved sorting quality 
• Reduced contamination 
• More efficient recycling processes 
• Better alignment across borders 

Responsibilities: 
• Adapting infrastructure and communication 
• Aligning with new labelling standards 
• Supporting public education efforts 
• Collaborating with producers and policymakers 

By combining standardisation with behavioural insights and digital tools, the EU is addressing a long-standing barrier to better recycling outcomes. 

If you have any questions about the new labelling system, please reach out to our team at PRONEXA by submitting the QUICK OBLIGATION CHECK.

With the introduction of the Digital Battery Passport, the European Union is setting a new benchmark for transparency, compliance, and lifecycle management in the battery value chain. The Passport is a legally mandated digital dataset that accompanies a battery throughout its entire lifecycle. In accordance with the EU Battery Regulation (Article 77), it becomes mandatory from 18 February 2027 to industrial, electric vehicle (EV) and light mobility batteries. 

Each battery is linked to a unique digital identity, enabling authorised parties to access standardised information via interoperable systems. This creates a traceable data layer that links the stages of manufacture, use and disposal – something that has largely been missing from current waste management systems. 

Why Was It Introduced? 

The regulation is a response to a systemic challenge: fragmented and asymmetrical information flows across the entire life cycle of batteries. For companies responsible for the proper disposal of electronic equipment, this has long led to inefficiencies, safety risks and sub-optimal recycling rates. As the European Commission emphasises, the Digital Battery Passport is intended to close these gaps by ensuring uniform data availability across all stages of the value chain. A key issue it addresses is the lack of clarity regarding end-of-life responsibility, which has historically hindered the implementation of extended producer responsibility (EPR). 

Beyond compliance, the passport supports strategic policy objectives, including: 

• Increasing material recovery rates for critical raw materials 
• Improving traceability and environmental performance 
• Enabling circular business models, including second-life applications 

In this sense, it is not only a regulatory tool, but also an infrastructure for a data-driven circular economy. 

Who Does It Affect? 

From a legal perspective, the obligation applies to all economic operators placing relevant batteries on the EU market—manufacturers, importers, distributors, and Original Equipment Manufacturers (OEM). The passport introduces a new level of transparency that will likely become integral to compliance audits, reporting, and process optimization by the availability and expectation of using structured battery data. For producers, this marks a transition from largely material-drivenprocesses to increasingly data-informed decision-making. 

What Information Does It Contain? 

The Digital Battery Passport consolidates a comprehensive set of technical, environmental, and lifecycle-related data. Importantly, this information is not static but evolves over time, reflecting the battery’s actual use and condition. 

Core data categories include: 

• Material composition and battery chemistry
• Origin of raw materials and manufacturing details 
• Carbon footprint and sustainability metrics 
• Performance, durability, and state-of-health data 
• Repair, reuse, and repurposing history 
• End-of-life handling and recycling instructions 

For recyclers, this represents a significant operational shift. Access to standardised, reliable data enables more precise sorting, safer dismantling, and improved recovery of high-value materials. At the same time, it increases transparency regarding compliance with environmental and safety standards. 

Why Compliance Is Not Optional 

The Digital Battery Passport is the first legally binding Digital Product Passport (DPP) in the EU – and as such, it establishes a precedent for other product categories. Its implications go beyond reporting obligations. The passport will be directly linked to regulatory compliance, meaning that non-compliance can restrict market access. In practical terms, this elevates data management and traceability to a critical business function. It affects all players in the value chain, not only the manufacturers: While the highest responsibility of course lies on them, also importers, distributors and other economic players will have to play their role and ensure that all formal requirements of the batteries are met that they would like to put on the market within the EU. 

For producers the message is clear:
the transition to a data-centric regulatory environment is underway. Early alignment with the requirements of the Digital Battery Passport will not only ensure compliance but also position companies to operate more efficiently in an increasingly complex and resource-constrained system.

For manufacturers of electrical and electronic equipment (EEE), the crossed-out wheelie bin symbol is often seen as nothing more than a regulatory formality. In reality, it is a key instrument of EU waste policy, linking product design, consumer behaviour and end-of-life management within the circular economy. 

The symbol is required by Directive 2012/19/EU on waste electrical and electronic equipment (WEEE). Manufacturers placing electrical and electronic equipment on the EU market must ensure that products are marked in accordance with the following provisions: 

• Article 14 of the Directive (information for users) 
• The technical labelling standard EN 50419 

This obligation is not merely administrative in nature. It ensures that environmental information reaches the end user directly at the point where decisions about disposal are made. 

Why Most Symbols These Days Contain a Black Bar 

Many products have a solid black bar under the wheelie bin symbol. This detail has a specific legal meaning: the bar indicates that the product was placed on the EU market after 13 August 2005, the cut-off date specified in the original WEEE Directive, which makes it possible to distinguish between the following products: 

• Historical WEEE that was placed on the market before this date (for which the end user has the responsibility of collection and recycling)
• New WEEE that was placed on the market after this date (for which the producer has all related obligations, being the first one to put the product onto the market in a specific country) 

This distinction remains important for authorities and PROs, as it helps to determine financial responsibility for waste disposal. 

A Direct Means of Communication for End Users 

The crossed-out wheelie bin is one of the EU’s most direct means of communication in the field of environmental protection. It is intended to inform consumers that electrical and electronic equipment must not be disposed with unsorted waste. By stipulating that the label must be visible, legible and durable, the directive ensures that private end users as well as professionals understand that they must: 

• dispose equipment via separate collection systems 
• avoid unsorted and mixed waste 
• return products to authorised WEEE collection points 

This simple visual signal is not a sign that the product and the producer are registered and compliant, a frequent misunderstanding we are facing in our daily operations.

Why the Symbol Is Important For Producers 

From a systems perspective, correct labelling directly contributes to the efficiency of collection and material recovery. In this way, the symbol not only supports compliance with legal requirements, but also operational efficiency along the entire waste management chain. Clear information for end users helps to:

• reduce the amount of WEEE ending up in residual waste 
• increase recovery rates for valuable materials such as copper, aluminium and rare earth elements 
• limit environmental and health risks from hazardous components 
• improve overall collection rates for WEEE, an important performance indicator under EU law 

While authorities carry out awareness campaigns to improve separate collection, product labelling remains the only information permanently affixed to the device itself – it is therefore a fundamental element of the WEEE system. 

Should you require further information about the crossed-out bin icon or your obligations as a producer under EPR regulations, do not hesitate to reach out to us via our Quick Obligation Check.

Batteries may be small, but the regulatory changes around them are significant. Since January, the new EU Battery Regulation has begun reshaping compliance across Europe, with its key provisions officially binding as of August 2025. For manufacturers and distributors, this isn’t just a legal update – it’s a shift toward new reporting structures, revised categories and adjusted processes. So what does this transformation actually mean in day-to-day business terms? 

Until now, batteries have been reported primarily according to their chemistry and weight. With the new regulation, the focus is now more on the actual use of the battery in the respective device or area of application. The new classification comprises five categories: 

• Portable batteries (≤ 5 kg) – e.g. in mobile electrical devices 
• Industrial batteries (> 5 kg) – for industrial applications
• LMT batteries (Light Means of Transport) – e.g. for e-bikes or e-scooters 
• SLI batteries (Starting, Lighting, Ignition) – typically for vehicles with combustion engines 
• EV batteries – for electric and plug-in hybrid vehicles 

A good example is the rechargeable lithium-ion battery: it can be found in all five categories – from smartphones and power tools to electric cars. So it is not just the battery itself that is decisive for reporting, but what it is used for. 

Adjustments in Reporting: New Categories in the Reporting Systems 

To reflect this differentiation, the European take-back systems (PROs – Producer Responsibility Organisations) have revised their reporting categories. The PRONEXA reporting tool (CDM platform) already reflects these changes. Companies will see the new categories in their monthly volume reports from January onwards and will have to allocate their battery sales volumes accordingly. 

In practice, this means: 

• Products that were previously reported under old categories must be reassigned. 
• Correct classification according to application is crucial for legally compliant reports. 

Are There Any New Legal Obligations? 

For many battery manufacturers and distributors who are already registered, the basic obligations remain the same. Nevertheless, there are specific new requirements for action in individual countries. 

1. Example Germany: Some existing battery contracts with take-back systems must be resigned or amended to comply with the new regulatory requirements. 
2. Example Denmark: There is an important change for foreign manufacturers here: they must now also register and report batteries – both as spare parts and integrated into electrical appliances. 

Regulations have also been tightened in other countries where previously no reporting obligation existed for foreign producers. Companies must now also register and report there– in line with the regulations in other EU countries. 

New Price Lists and Conversion of Existing Reports 

With the new Battery Regulation, many PROs have also adjusted their price structures. This has several practical consequences: 

• Manufacturers must transfer their previously reported products to the new categories in order to be able to report correctly from January onwards. 
• In some countries, new registration requirements are being introduced for companies that were not previously subject to reporting obligations. 
• Existing contracts with take-back systems – for example, in Germany – may need to be updated. 

Conclusion:
Review Your Processes and Adjust Reports Now 

The new EU Battery Regulation does not introduce entirely new obligations, but rather a more precise, application-oriented system – with direct implications for reporting, contract structures and national registration requirements. 

Companies should: 

• assign their product portfolios to the new battery categories 
• review national specifications 
• review existing contracts and registrations 

If you are unsure about the new EU Battery Regulations and its impact on you as a producer, it is advisable to contact your responsible PRONEXA Compliance Specialist directly.
If you are not a PRONEXA customer yet, please use the QUICK OBLIGATION CHECK.

PRONEXA Compliance Specialists support companies in identifying necessary adjustments and implementing them in a legally compliant manner.

An important milestone will be the publication of the Design for Recycling (DfR) guidelines by January 2028. These guidelines will define when packaging is officially considered recyclable, and according to the PPWR, this requirement extends far beyond theoretical standards.  

Packaging must:  

• be sortable in existing waste streams
• be recyclable in efficient industrial processes, 
• produce secondary raw materials that can replace virgin materials. 

At the same time, recyclable packaging will be rewarded with lower EPR fees through eco-modulation, while formats that are difficult to recycle will be subject to higher costs. As existing forms of eco-modulation already show, implementing these changes will be challenging in practice and very difficult to monitor.  

2030: Recyclability as a Market Requirement 

From 2030, packaging must be at least 70% recyclable to enter the EU market. Stricter rules, including the Recycled at Scale (RaS) requirement from 2035, will tie recyclability to real recycling rates. Additional measures like single-use plastic bans and reuse targets will change packaging and infrastructure further. 

Mandatory Recycled Content in Plastics 

The PPWR sets required recycled content levels for plastic packaging:  

• 2030, ranges between 10% and 35%, based on plastic type,  
• 2040, rising to 25%–65%.  
• Exceptions cover some medical or pharmaceutical packaging, and packaging with less than 5% plastic. These rules aim to drive demand for high-quality recyclates in critical uses. 

By 2026, the European Commission will set standard rules for calculating and verifying recycled content to improve market transparency and regulation enforcement. Eco-modulation means packaging with higher recycled content may cost less, depending on national implementation.  

Recycled at Scale (RaS): Integrating Design With System Effectiveness 

The RaS requirement introduces an additional critical aspect. Packaging qualifies as recyclable only if it is recycled to a substantial degree within designated material streams. This criterion establishes a direct connection between product design and the real capabilities and performance of recycling systems. Although some requirements are still far off, current reports for packaging already demand recycling data and evidence. 

Packaging Data That You Are Required to Report 

We assist you with your packaging reporting and submit your regular reports to the PROs or authority bodies. In this report, you list the amount of packaging you introduce to the market or country. The authority uses this information to calculate the material recycling rates (%) of recycled packaging. After submitting the report with material and packaging amounts, an invoice will be generated. 

Reporting to PROs or Authority Bodies  

Report packaging volumes in kilograms for all packaging types you put on the market, specifying if they are for households or other uses. Include packaging made from these materials in your report:  

• cardboard/paper,
• wood,
• glass,
• metal (steel or aluminium),
• plastics and 6. other packaging materials (such as ceramics and textiles). 

Recyclability and Reporting by Recycling Grade
(e.g., Denmark, Sweden, Finland, France, UK)  

A number of countries have established graded recycling systems, featuring tiered fees according to the recyclability of packaging. These fees range from green (lower rates) to amber and red (higher rates).  

In Sweden, both rigid and flexible mono-material plastic packaging can be easily identified through modern sorting technology, which streamlines material separation and improves downstream recyclability. This results in higher recycling rates and significant cost reductions for customers. Moreover, bonuses are awarded for paper and cardboard that are not laminated or coated, as these materials dissolve more readily during recycling, especially within paper mills. 

To sum up, every EPR fee takes into account that mono-materials are simpler to sort and recycle, making them ideal for creating secondary raw materials. Regulations encourage replacing virgin materials with recycled alternatives. Additionally, colourinfluences sorting and recycling processes, which is why some countries require reporting by clear or coloured packaging. 

By adopting Design for Recycling (DfR) principles in your packaging, your organisation can fulfil regulatory obligations and lower expenses. 

Reporting Requirements for Single-Use Plastic (SUP) Products 

For packaging reports in Nordic countries like Sweden and Finland, companies must identify any single-use plastic items in their product portfolio. If your company has single-use plastic products (e.g. plastic carrier bags), you are required to report their quantities in your SUP submission.  
Future updates will cover more details on single-use plastics and packaging, including EPR stream information. 

Need Help With Complex Reports Across Different Countries?  

Contact us via our QUICK OBLIGATION CHECK to learn which obligations apply.
We provide consulting and operational support for importers, producers, and resellers of packaging and packaged goods. 

It’s a striking figure: every EU citizen generated 177.8 kg of packaging waste in 2023, according to Eurostat. The environmental and economic implications are impossible to ignore – escalating resource consumption, loss of valuable materials, and rising regulatory pressure on businesses. 

The EU’s response is the Packaging and Packaging Waste Regulation (PPWR). Unlike a directive, this regulation applies directly across all Member States since 11.02.2025, while most of its obligations and legal requirements will kick in as from 12 August 2026, leaving no room for national interpretation or delay. Its mission is clear: prevent unnecessary packaging, drive reuse, and significantly increase recycling rates. By 2030, at least 70% of all packaging waste must be recycled, with ambitious material-specific targets for plastics, paper, glass, metals, and wood. 

Are You a “Producer” Under the PPWR? 

But there is one aspect many companies underestimate: The PPWR introduces a new, much clearer definition of who is the “producer”. And this matters — because the “producer” becomes the central responsible party for compliance and Extended Producer Responsibility (EPR). 

This is where many businesses will be affected – even those who never considered themselves packaging producers before. The New PPWR Definition of “producer” (Art. 3.15) is defining a producer as the economic operator who first makes packaging or a packaged product available on the market of a Member State, whether as: 

• a manufacturer
• an importer 
• a distributor 
• an e-commerce operator 
• a brand owner 
• or a contract giver 

The objective is simple: every packaging unit should have one clearly identifiable responsible producer. 

The Contract Giver Becomes the Producer

The contract giver is automatically the producer – that is one of the most impactful changes. If you have packaging or packaged products manufactured under your own name or trademark, you are considered the producer, even if: 

• another company physically manufactures the product, 
• another brand name appears on the packaging, 
• production happens outside the EU. 

This means, the contract giver becomes legally responsible for the packaging. All EPR obligations fall to them, including fees, reporting, design requirements, and compliance documentation. 

Why This Matters for Your Business 

The new definition of a manufacturer under PPWR includes any natural or legal person who manufactures packaging or packaged products – or the customer who commissions this manufacturing. As a result, the roles of “manufacturer” and “producer” merge in many cases, thereby increasing responsibility. Responsibility may shift within a supply chain: companies that were previously ‘only distributors’ or “only brand owners” may now be classified as producers – with full compliance obligations. 

You should check: 

• Do you place packaging or packaged products on the EU market for the first time? 
• Do you sell under your own brand or trademark? 
• Do you commission manufacturing or packaging through third parties? 
• Do you import packaged goods into the EU? 
• Do you operate an online shop targeting EU customers? 

If any of the above points apply, you may be the obligated manufacturer under PPWR. You will then need to assess your role in the supply chain.

What you need to do now: 

• Map your packaging flow across countries and partners. 
• Analyse design, recyclability, and minimisation requirements. 
• Prepare for EPR obligations in all relevant Member States. 
• Establish documentation and conformity processes early. 
• From 2026, compliance will no longer be optional — and the responsibility will be clearly assigned. 

Need Help With EU Packaging Compliance? 

The PPWR is reshaping responsibilities across the entire packaging value chain.
If you are unsure whether your company is considered a “producer” or how the regulation affects you, please contact us by answering 5 simple questions in our Quick Obligation Check.